Investigations to assess sources of contamination in the soil and ground water at the Dominion Energy Brayton Point Station were performed under both the solid waste and MCP regulations.  Of particular concern was whether oil ash landfill cells were leaking and whether there were impacts to the salt water and freshwater wetlands of Fox Hill Cove.

Under the direction of the project manager at Roux Associates, a regulatory strategy was developed, proposed and approved that allowed Brayton Point Station to consolidate investigations under the MCP and then, if appropriate, revert back to the solid waste regulations.  This benefited Brayton Point Station as the MCP investigation process is streamlined and may proceed without regulatory oversite and approvals.

The MCP investigations resulted in findings and conclusions that 1.) The landfill cells were not leaking; 2.) Contamination in the soil, groundwater, and wetlands was the result of historical oil ash settling basins; 3.) No significant risk to human health was present at the site under current uses; and 4.) A potential risk of harm was present in the wetlands based upon food chain modeling.

In 2006, it was agreed to divide the site into two areas for the purposes of future regulations.  Area 1, including the permitted landfill cells and the wetlands of Fox Hill Cove, were regulated under the Massachusetts Solid Waste Regulations while Area 2, which included the highest concentrations of contaminants in soil and ground water and unpermitted landfill Cell 1A, were regulated under the MCP.

Roux Associates completed a Corrective Actions Alternatives Analysis for Area 1 under the solid waste regulations that focused on assessing the alternatives to address the potential risk of harm in the wetlands from the contamination attributable to historic oil ash releases.  A detailed alternatives analysis, relying upon the scientific data generated during previous investigations, resulted in the recommendation of No Further Action as the best alternative.  On July 3, 2008, the Massachusetts Department of Environmental Protection (MassDEP) concurred with this opinion resulting in a savings of over $10,000,000 in wetland remediation and restoration costs to Dominion.

Area 2 is currently being remediated under the MCP following the completion of a remedial alternatives analysis and design.  Cell 1A is being remediated by replacing the degraded PVC cap with a new HDPE liner and paving the areas adjacent to the landfill cell with the highest concentrations of oil ash contamination in the soil and groundwater.  The objectives of the caps are to prevent water infiltration and the leaching of contaminants to the groundwater.  It is anticipated that regulatory closure will be achieved for Area 2 by the end of 2008.

In addition to the remedial alternatives analysis and actions described above, Roux Associates has been supporting Dominion Energy on development activities and plans for Areas 1 and 2.